Estrada vs. Sandiganbayan

G.R. No. 148560 November 19, 2001

FACTS:

On April 4, 2001, the Office of the Ombudsman filed before the Sandiganbayan eight (8) separate Information against President Joseph Ejercito Estrada, the highest-ranking official,  for violation of the Plunder Law (Crim. Case No. 26558), Anti-Graft and Corrupt Practices Act (Crim. Cases Nos. 26559 to 26562), The Code of Conduct and Ethical Standards for Public Officials and Employees (Crim. Case No. 26563), Perjury (Crim. Case No. 26564), and Illegal Use Of An Alias (26565).

On April 11, 2001, petitioner, bewails the failure of the law to provide for the statutory definition of the terms “combination” and “series” in the key phrase “a combination or series of overt or criminal acts” found in Sec. 1, par. (d), and Sec. 2, and the word “pattern” in Sec. 4. These omissions, according to petitioner, render the Plunder Law unconstitutional for being impermissibly vague and overbroad and deny him the right to be informed of the nature and cause of the accusation against him, hence, violative of his fundamental right to due process.

ISSUE

(1) Whether or not the Plunder Law is vague or ambiguous, thus denies the petitioner of right to be informed of the nature and cause of the accusation against him, hence, violative of his fundamental right to due process

HELD

(1) NO, the Plunder Law contains ascertainable standards and well-defined parameters which would enable the accused to determine the nature of his violation; As long as the law affords some comprehensible guide or rule that would inform those who are subject to it what conduct would render them liable to its penalties, its validity will be sustained.  A statute is not rendered uncertain and void merely because general terms are used therein, or because of the employment of terms without defining them; much less do we have to define every word we use. Besides, there is no positive constitutional or statutory command requiring the legislature to define each and every word in an enactment. Congress is not restricted in the form of expression of its will, and its inability to so define the words employed in a statute will not necessarily result in the vagueness or ambiguity of the law so long as the legislative will is clear, or at least, can be gathered from the whole act, which is distinctly expressed in the Plunder Law.

Moreover, it is a well-settled principle of legal hermeneutics that words of a statute will be interpreted in their natural, plain and ordinary acceptation and signification,7 unless it is evident that the legislature intended a technical or special legal meaning to those words.8

DISPOSITIVE PORTION

In view of all the foregoing, the petition for mandamus is granted and, there appearing no reasonable objection to the use of the Plaza Miranda, Quiapo, for the meeting applied for, the respondent is ordered to issue the corresponding permit, as requested. So ordered.

DOCTRINE

A statute or act may be said to be vague when it lacks comprehensible standards that men of common intelligence must necessarily guess at its meaning and differ in its application. In such instance, the statute is repugnant to the Constitution in two (2) respects—it violates due process for failure to accord persons, especially the parties targeted by it, fair notice of what conduct to avoid; and, it leaves law enforcers unbridled discretion in carrying out its provisions and becomes an arbitrary flexing of the Government muscle.

The void-for-vagueness doctrine states that “a statute which either forbids or requires the doing of an act in terms so vague that men of common intelligence must necessarily guess at its meaning and differ as to its application, violates the first essential of due process of law.”

The overbreadth doctrine, on the other hand, decrees that “a governmental purpose may not be achieved by means which sweep unnecessarily broadly and thereby invade the area of protected freedoms.”

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